For example, if (1) the taxpayer did not loan the pledged shares to the counterparty until six months after the VPF was entered into, (2) there was no pre-existing agreement that such a loan would ever take place and (3) the counterparty paid an arm's-length fee for borrowing the shares, would the stock loan and the VPF be viewed as part of one agreement?

The proposed regulations with respect to hedges by members of consolidated groups are to be effective for transactions entered into on or after the date that is 60 days after the publication of final regulations in The Federal Register.

58) Both sets of regulations also provide guidance on when two contracts entered into between the same parties should be aggregated (without regard to the order in whihc the contracts were entered into or performed and without regard to whether one of the contracts could actually be performed without the prior or contemporaneous performance of the other).

Finally, the taxpayer could have assigned income rights under an existing swap that it had entered into in connection with its business, or at least tried to match the swap with the items that it claimed to be hedging.

Nasdaq:EQIX), the leading provider of network-neutral data centers and Internet exchange services, today announced that it has entered into a sale-leaseback agreement for the data center property it recently purchased in the Los Angeles area.

The character of the gain or loss realized on the July 1, 1999 sale of the long position would be long-term, because the short sale against the box was not deemed to be a constructive sale and the ABC stock had a long-term holding period when the short sale was entered into.

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